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MTTC Open Letter in response to Minister Gail Shea, PC, MP

Monday, August 31st 2009 5:17:26pm

August 31, 2009

Minister Gail Shea, P.C., M.P
Fisheries and Oceans Canada
200 Kent Street
Ottawa, ON,   K1A 0E6
VIA FACSIMILE: 613-990-7292

Dear Minister Shea:

We write in response to your letter to Don Staniford, Global Coordinator for the Pure Salmon Campaign, dated August 26, 2009.  As you are aware, I was a signatory to that letter in my capacity as Chief of the Kwicksutaineuk Ah-Kwa-Mish First Nation (K-AFN) and Chairman of the Musgamagw-Tsawataineuk Tribal Council (MTTC).  I write this letter on behalf of the four Nations of the MTTC.

The issues raised in the Pure Salmon Campaign correspondence, both in our original letter to the King of Norway, in which you were copied, and in your response letter, are of the utmost significance and importance to the MTTC membership.  We rely on the salmon fisheries for subsistence and cultural survival and as such, we possess constitutionally protected rights to the salmon fisheries in our traditional territories under s. 35 of the Constitution Act.  On several previous occasions, we put your Ministry on notice that the salmon stocks we traditionally rely on have not been available in sufficient abundance for us to meet our basic food, social and ceremonial needs.  We therefore reviewed your letter closely and have a number of serious concerns with the inadequacy of your response that I am obliged to communicate to you on behalf of the membership.

At the outset, there is no publically available, peer reviewed science that indicates the reason for the coast wide decline of wild Pacific salmon species is related solely to climate change and broader ecological changes in ocean productivity on the British Columbia coastline.  Your assertion is simply not founded on evidence.  With respect to the present collapse of the Fraser River sockeye fishery, for example, it is clear on the public record that the Department of Fisheries and Oceans predicted an abundant return as recently as the spring of 2009 and had no explanation when these stocks failed to materialize.  

As you should be aware, there is significant evidence that salmon farms continually contribute to the decline of wild salmon stocks.  While we recognize that it may not always be clear to what proportion the presence of salmon farms contribute to the decline of wild stocks, there is a clearly documented connection.  Given the fact that the Department of Fisheries and Oceans Canada has a significant level of control over the regulation of salmon farming relative to other factors such as global warming, we simply cannot understand why you would not take a precautionary approach to minimize this risk to wild salmon.  Your letter reflects an approach of denial and/or ignorance, in our view.

You stated that \"DFO ensures that all aquaculture operations are subject to rigorous environmental standards under a number of statutes and regulations, including the Fisheries Act and the Canadian Environmental Assessment Act [CEAA], to ensure our marine ecosystems are not compromised\".  With respect, this statement is completely inaccurate in relation to the thirty-one salmon farms within MTTC traditional territories.  Environmental assessments under the CEAA have been completed for only two of the thirty-two existing sites.  We were approached by Canada to participate in a consultation process with respect to the assessments over three years ago.  In February 2008 (in the absence of any capacity support from Canada), we provided detailed input to the environmental assessment process.  Eighteen months have passed and we have yet to receive a response.  As I understand it, all but two of the salmon farms currently operating in our traditional territories are doing so without the legally required approvals under the CEAA.   This is a shocking and utterly unacceptable state of affairs.  It makes the statements in your letter appear false to an embarrassing proportion.  

Your letter stated that \"the industry has also developed coordinated management in the Broughton Archipelago to remove fish from pens on these routes in advance of and during juvenile migration\".  The Broughton Archipelago is where our members live, and we are well aware of the coordinated management plan developed by the industry operating in our territory.  This management plan has been opposed by us from the outset because it includes doubling the volume of farmed fish in both the Tribune-Fife corridor and the Lower Knight corridor in alternate years to maintain the total volume of farmed fish in the Broughton Archipelago.  This means that in order to manage the expected increase in sea lice on a particular corridor in a given year, the farms will require an increased level of chemical treatment (SLICE), with associated impacts on the sea floor and on bottom fish, shellfish and seaweeds.  

Of equal concern to us in respect of your statement is the fact that this is a voluntary management strategy on the part of industry that was not developed, and is not enforced, by the Department of Fisheries and Oceans.  In our view, the DFO has abdicated its responsibility for wild salmon to the industry, whose goal is profits and not long term public interest, including prioritizing First Nations rights.  As you should be aware, the MTTC has developed a comprehensive regional management plan for the Broughton Archipelago.  We have sort every opportunity to engage with Canada and the Province to implement this plan and have not progressed to date.

Finally, with respect to closed containment research, the studies and research DFO has undertaken to date in this area are very limited.  While in Norway did you visit the Preline closed containment farm in the Bergen Region?  If you acknowledge that \"there are potential technologies that show promise for improving Atlantic salmon production and for restricting and controlling interactions\", we ask why your Department is not devoting significant resources to implement these.  We have no knowledge of the socio-economic analysis you indicate is underway to help inform potential pilot projects in the future and we request information, and input, on the same.  

In sum, we find your letter to be uninformed and unsatisfactory, at best.  We request a meeting with you in person to discuss our concerns.


Chief Robert Chamberlin, MTTC Chairman